The policy applies to personal data provided to Counterpart International, Inc. (Counterpart), both by the individual themselves and by others and what their rights are regarding the data.
Collection of Personal Data
For the purposes of this policy, personal data is information in any format that relates to a living individual who can be identified by that information, either on its own or when it is combined with other information held by Counterpart.
Counterpart does not collect Personally Identifiable Information (PII) for persons under 16 years of age.
Counterpart will only collect personal data when necessary for business-related purposes. The data may be collected directly from the individual for the agreed purposes of employment, consideration for employment, assistance in making donations, informing you about goods or services we provide, providing services to you, executing contracts and or agreements, or keeping people informed about Counterpart’s work.
The types of Personal Data Counterpart may collect includes, but is not limited the following:
- Name and address
- Gender, marital status and date of birth
- Telephone and email
- Employment history, qualifications, and skills
- Forms I-9, W8BEN, W9
- Banking and transfers
- Information provided digitally through Counterpart’s websites, applications, associated sites, outreach activities, or social media accounts
You have choices when it comes to the data you share. When we ask you to provide personal data, you can decline. Many of our services and engagements some personal data to provide you with a service. If you choose not to provide data necessary to provide you with a service, we cannot engage you regarding that service. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing service or relationship with Counterpart, we may have to suspend or cancel it. We will notify you if this is the case at the time.
Personal Data is collected through our interactions with you and through our products and services. The data we collect depends on the context of your interactions with Counterpart and the choices you make, including the services you use and the way you engage Counterpart. This includes:
- Application for employment submitted by the individual
- Through government agencies or third-party reporting services as legally required
- Details provided by the individual regarding disabilities and any accommodations Counterpart may need to make in the workplace
- Information provided by the individual through direct communication between the individual and Counterpart personnel, such as email, mail, by telephone and direct meetings
- Applications by the individual to attend events such as conferences, meetings and trainings
- Photos and videos of your attendance at training events or similar sessions
- Enquiries made by individuals through our websites and comments made through our websites or social media accounts
- Your interaction with us through social media accounts, registers, subscriptions or email communications (e.g. through a subscription to Counterpart’s mailing list)
Counterpart relies primarily on consent from individuals to collect, process, and hold their data. An individual may choose to not provide consent or not provide certain personal data. If an individual chooses not to provide consent or key data, Counterpart may not be able to provide the individual with services or contract with them.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Counterpart International to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting firstname.lastname@example.org.
Transfer of Personal Data
We may pass your personal data on to third-party service providers contracted to Counterpart International while dealing with you only if strictly necessary for the reasons stated above.
Any third parties that we may share your data with are obliged to keep your details securely, and to use them only assist us in performing our services.
When they no longer need your data to fulfil this service, they will dispose of the details in line with Counterpart International’s procedures. If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent unless we are legally required to do otherwise.
Counterpart will only share your personal data when legally permitted or required to do so. Counterpart includes contractual language with third-parties regarding data protection, confidentiality, and secure guidelines to ensure that the transfer will be under an agreement which covers the EU GDPR requirements.
Personal information that Counterpart holds may be transferred to the following types of organizations:
- Third-party organizations that provide support services such as payroll, travel, health insurance, and others
- Professional advisors such as lawyers, auditors, and accountants
- Law enforcement, government, or other regulatory agencies as provided by law
Retention of Personal Information
It is Counterpart’s intent to not keep personal information for longer than reasonably required. The retention period depends on the nature of the personal data and the purposes for which it was received. Counterpart has a Document Retention Policy that lays out the retention period for all manners of data. The Data Retention policy has been created based on best practices for our sector.
At any point while Counterpart is in possession of personal data, data subjects who are EU residents have the following rights:
- Right to Access: Subject to certain conditions, you have the right to access the information Counterpart holds on you. You can request a copy of the information.
- Right to Correction: You have the right to correct data that Counterpart holds that is inaccurate or incomplete.
- Right to be forgotten: In certain circumstances, you can request that data Counterpart holds be erased from our records.
- Right to Object to or Restrict Processing: When certain conditions apply, you have the right to object to or ask Counterpart to restrict the processing of your personal data.
- Right to Data Portability: You have the right to have the data Counterpart holds on you transferred to another organization.
- Right to Object: You have the right to object to certain types of processing such as direct marketing.
- Right to Withdraw Consent: Where Counterpart’s processing of your personal data is based on your consent, you have the right to withdraw your consent. However, it will depend on Counterpart’s legal obligations.
To process the above, Counterpart may need to request additional information from you to confirm your identity. Any request will be responded to in accordance with regulatory requirements once your request has been determined valid. See Contact and Complaints Request section for further guidance.
Breaches of Personal Data
All personal data is protected, and measures and procedures are in place to minimize the risk of unauthorized access or disclosure; Counterpart adheres to best practices to protect personal data, including encryption when the data is in transit between systems or stored at any location; providing access to data on a need-to-know basis; and performing periodical internal and external security evaluations of its controls and information security practices.
Counterpart will respond to any breach as required by the regulation. If anyone becomes aware of a data breach, they should contact email@example.com immediately.
Images Utilized by Counterpart
Counterpart utilizes images collected by our staff to demonstrate the nature and impact of our work. Counterpart seeks consent to the degree practical from the individuals depicted in these images. If your likeness is reproduced in any of the image to be deleted, please contact Counterpart and the images will be promptly removed.
Contact for Requests and Complaints
If you would like to submit a request regarding your personal information or to submit a complaint, please submit a request to firstname.lastname@example.org.
Cookies are small pieces of data, stored in text files, that are stored on your computer or other device when websites are loaded in a browser. They are widely used to “remember” you and your preferences, either for a single visit (through a “session cookie”) or for multiple repeat visits (using a “persistent cookie”). They ensure a consistent and efficient experience for visitors, and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that you are visiting (known as “first party cookies”), or by third parties, such as those who serve content or provide advertising or analytics services on the website (“third party cookies”).
Both websites and HTML emails may also contain other tracking technologies such as “web beacons” or “pixels.” These are typically small transparent images that provide us with statistics, for similar purposes as cookies. They are often used in conjunction with cookies, though they are not stored on your computer in the same way. As a result, if you disable cookies, web beacons may still load, but their functionality will be restricted.
Some cookies will be used if you are a registered user (so you don’t have to log in every time, for example), while others are set whenever you visit one of our websites, irrespective of whether you have an account. We set cookies in different locations across our websites.
For more information on the choices you have about the cookies we use, please see the Controlling Cookies section below.
The table below explains the types of cookies we use on our websites and why we use them.
Strictly Necessary: These cookies are essential for websites on our services to perform their basic functions. These include those required to allow registered users to authenticate and perform account related functions.
Functionality: These cookies are used to store preferences set by users such as account name, language, and location.
Security: We use these cookies to help identify and prevent potential security risks.
Analytics and Performance: Performance cookies collect information on how users interact with our websites, including what pages are visited most, as well as other analytical data. We use these details to improve how our websites function and to understand how users interact with them.
Advertising: If the website offers any advertising, these cookies are used to display relevant advertising to visitors who use our services or visit websites we host or provide, as well as to understand and report on the efficacy of ads served on our websites. They track details such as the number of unique visitors, the number of times ads have been displayed, and the number of clicks the ads have received.
Third Party / Embedded Content: These include social media platforms such as Facebook and Twitter (using sharing buttons), or embedded content from Youtube and Vimeo. As a result, cookies may be set by these third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising visit youronlinechoices.eu (EU-based) or optout.aboutads.info (US based). On a mobile device, you may also be to adjust your settings to limit ad tracking.
You can opt out of Google Analytics by installing Google’s opt-out browser add-on.
You may see a “cookie banner” on our websites and dashboards. We do not set, or allow our ad partners to set, cookies that are used to show you targeted ads before you click to accept. When you consent in this manner, we and our advertising partners may set advertising cookies on the site you are visiting and on other of our websites, dashboards, and services.